A Global Perspective on Packaging

D. Grant Lawrence of the European Commission lays out the concept of producer responsibility for pallets.

After listening to politicians and academicians for several days at the Take It Back 2002 conference,

I came up with a new spin on the chicken/egg conundrum: Who cares which comes first? More importantly, is the egg’s shell part of the product or part of the package?

I was trying to follow the logic of keynote speaker D. Grant Lawrence, director for sustainable development and policy support, European Commission (EC). He told me there are a multitude of issues surrounding forthcoming recycling regulations that pertain to packaging. In Europe — and the trend is growing elsewhere — the thinking is that the polluter should pay for disposal of waste. Polluter is defined as the manufacturer of the product. It’s termed producer responsibility.

The example Lawrence used was this: If you purchase a potted plant at a garden center, is the pot part of the product or is it the package? If it’s part of the product (and how could you carry the plant from the store without the pot?), the manufacturer, in this case the grower, is responsible for the disposal of the pot. But if the container is packaging (and how could you carry the plant from the store without the pot?), the consumer is responsible for its disposal.

Oh, my! This ain’t gonna be easy.

Closer to home is the issue of pallets. I asked Lawrence how this line of thinking applies to pallets — plastic or wood — used to ship products to Europe and who will be deemed responsible for disposal. It was like tossing an underhand pitch to Sammy Sosa.

“Well, now,” he said with the careful response of a politician, “that’s a very interesting question!” Lawrence found it interesting because, given current thinking, all pallets might not be treated equally. Pallets might be judged by content rather than function.

What does that mean? Well, plastic pallets would probably be part of “targets” or objectives companies would be trying to hit, i.e., 20 percent recycled plastic, or whatever. They might even generate some money when sold to recyclers. Whereas wood could fall into the “packing waste” category, subject to different restrictions and, importantly, different disposal fees, creating a burden for manufacturers or users.

On another front, pallet phytosanitary issues continue to be a concern when talking about exporting to Europe. And the list of nations outside of Europe (30 by my estimation) with similar laws on their books is growing.

Let’s eradicate the bug issue once and for all. It appears that regulations governing the entrance of non-manufactured wood packing material into the EU will be a done deal by the time you read this. At the end of March, the EC was to take its final vote requiring heat treatment, fumigation or pressure treatment of all imported non-manufactured wood packing material. Hardwoods are included in the final restrictions. These requirements will have a major impact on pallet users.

It was first thought the requirements would apply only to coniferous wood species. Not so. I had the opportunity to speak with Bill Snell, a plant health specialist with the U.S. Department of Agriculture. He’s been fighting these battles for 27 years. He told me, on this side of the pond we’re regularly defending against the import of nearly 1,200 pests. We taxpayers spend about $9 million just to contain the Asian longhorned beetle.

“The EU requirements [covering all species of wood] are just part of a global, environmental issue,” says Snell. “The debarking part of the requirements will be particularly challenging since about 25 percent of the hardwoods in pallets are not debarked.”

I looked for a silver lining in this storm brewing across the ocean. The requirements might enhance the use of higher-quality pallets, encouraging reuse rather than disposal. Or, the requirements might stimulate the use of manufactured wood with its inherent benefits.

Clyde E. Witt, executive editor, [email protected]

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